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Welcome to 1100 Pennsylvania, a newsletter devoted to President Donald Trump’s Trump Hotel International Washington, D.C. (and his other companies). President Trump, of course, still owns his businesses and can profit from them.

If you like what you see, tell someone—and support this work by paying for a subscription. If you’ve been forwarded this newsletter, subscribe for yourself at zacheverson.substack.com.Tips or feedback? Contact me, Zach Everson, securely via email at 1100Pennsylvania@protonmail.com or on Signal at 202.804.2744.

Dominica’s United Nations ambassador received a free Mar-a-Lago NYE ticket

The Commonwealth of Dominica’s ambassador to the United Nations, Paolo Zampolli, said he attended Mar-a-Lago’s New Year’s Eve celebration as a guest of the Trump family and his country’s government did not pay the president’s private club for his ticket. A photo Zampolli posted on Instagram, which 1100 Pennsylvania reported about yesterday, showed him seated with the First Lady and lamenting the U.S. president’s absence.

“I’m friends with the president 25 years,” Zampolli said via the phone Wednesday afternoon. “It’s not like we paid to go there. I was asked as a guest at a family table the last three years.”

When asked specifically if Dominica paid Mar-a-Lago for his ticket, Zampolli said, “Absolutely not, it had nothing to do with my position.”

As Zampolli introduced Trump to his now wife(who worked for Zampolli’s modeling agency at the time) and Zampolli once was the Trump Organization’s director of international development, his explanation is quite plausible. A Trump Organization spokesperson, however, did not reply to a request to verify Zampolli’s account.

Of course, in the scenario Zampolli described,the U.S. president or his business gifted a ticket worth a reported $1,000 to a foreign government official.

That arrangement concernsthe executive director of Citizens for Responsibility and Ethics in Washington, Noah Bookbinder (CREW is a watchdog involved in two emoluments lawsuits against President Trump):

My best sense is that this gift does not violate laws or ethics rules, largely because several conflict of interest laws and rules don’t apply to the President. Nonetheless, it clearly creates a significant conflict of interest to have the President and his business conferring gifts on a foreign official whose country almost certainly has interests that affect the United States. This once again illustrates the perils of the President continuing to own his businesses.

This also raises some other questions. If the Trump Organization gave the tickets to the President, then that is a gift the President will need to report on his financial disclosure. If the President paid the Trump Organization for the tickets, he would not need to report it. If the Trump Organization gave the tickets directly to the President’s friend, did it do so at the President’s direction? That would seem to contradict the President’s assertion that he is not involved in the day to day management of the company.

White House deputy press secretary Lindsey Walters didn’t reply when asked if President Trump advocated for reopening of the tower. Similarly, the D.C. hotel’s managing director, Mickael Damelincourt, and spokespeople for both the Trump Organization and its D.C. hotel didn’t respond when asked if they lobbied for the tower to be funded during the shutdown or if the Trump Organization funded re-opening the tower itself.

1100 Pennsylvania has submitted a FOIA request to the GSA asking for additional information about how the decision to reopen the tower was reached and specifics about its funding.

Noteworthy sightings

Fox News pundit and Trump campaign advisor Harlan Hill was back at the hotel, posing here with former Trump 2016 staffer Healy Baumgardner. Post campaign, Baumgardner’s became a lobbyist for foreign clients; Open Secrets reported that her company received $250,000 from Malaysia.

Individual capacity—On Dec. 14, Trump’s personal attorneys appealed the denial of their motion to dismiss the case, also to the 4th U.S. Circuit Court of Appeals. On Dec. 19, the AGs replied to Trump’s motion for a stay pending that appeal by voluntarily dismissing the claims against Trump in his “individual capacity to allow the claims against President Trump in his official capacity to move forward expeditiously.” (The AGs only brought suit against Trump in his individual capacity after the judge suggested they do so.) Trump’s personal attorneys, on Dec. 21, opposed the motion to dismiss at the district level, saying the appeals court now has jurisdiction and accusing the AGs of “gamesmanship.”

Thanks for reading. If you like what you saw, tell someone—and support this work by paying for a subscription. If you’ve been forwarded this newsletter, subscribe for yourself at zacheverson.substack.com.Tips or feedback? Contact me, Zach Everson, securely via email at 1100Pennsylvania@protonmail.com or on Signal at 202.804.2744.